New Tax Laws on the Way…. Can They be Retroactive?

The question has often been asked whether Congress can enact retroactive tax legislation, in effect “setting back the clock” and making a law effective as if it had been enacted at an earlier point in time. The topic takes on special importance today as the Biden Administration is considering a vast magnitude of tax increases.  Taxpayers … Continue reading New Tax Laws on the Way…. Can They be Retroactive?

Senator Sanders – Gift and Estate Tax Reform Proposals Pack a Punch

Anyone out there thinking about estate tax planning, asset protection, making gifts? And, what about those considering expatriation?  I am fielding many more inquiries about expatriation these days.  Well, if you are considering any of these things, my sage advice would be to hurry up.  Major transfer tax law changes look  to be on the … Continue reading Senator Sanders – Gift and Estate Tax Reform Proposals Pack a Punch

GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

On November 8, 2020, I participated in a podcast with attorney John Richardson. We discussed some of the reasons why the incoming administration was likely to increase the pressure on Americans abroad. The podcast is here. On March 25, 2021 the Senate Finance Committee held a hearing on International Taxation. The hearing discussed changes to … Continue reading GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

What does Senator Warren’s Proposed Wealth Tax Mean for You?

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?

Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time.  This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR).  Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

COVID-19: Is Employer Provided Assistance due to the Pandemic Taxable Income? What if the Employer is “Foreign”?

Last week's blog post discussed the home office tax deduction and burst the bubble for many who were working at home for months under COVID-19 restrictions.  Unfortunately, as discussed in that earlier post, this tax break cannot be used by an individual who is an “employee” as opposed to "self-employed".  This restriction is a result … Continue reading COVID-19: Is Employer Provided Assistance due to the Pandemic Taxable Income? What if the Employer is “Foreign”?

GILTI High Tax Kick-Out Election — Kicked Out by Dems!

On February 12, Senate Finance Committee Ranking Member Ron Wyden, D-Ore., and Senator Sherrod Brown, D-Ohio, introduced legislation to prevent the Treasury Department from carving out an exception (commonly called the GILTI High Tax Kick-Out) for multinational companies to escape the so-called GILTI provisions of the Tax Cuts and Jobs Act (TCJA). The title of the … Continue reading GILTI High Tax Kick-Out Election — Kicked Out by Dems!

Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief

NEWS FLASH! The Internal Revenue Service (IRS) announced today that there are limited circumstances in which it may be appropriate to provide relief from "double taxation" resulting from application of the repatriation tax under Internal Revenue Code Section 965, as amended by the Tax Cuts and Jobs Act (TCJA). The IRS has determined that in … Continue reading Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief

ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses.  In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture.  This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Overseas Home? Mortgage Interest, Foreign Real Property Taxes & New US Tax Law – Any Workaround?

Sweeping tax reform was signed into law by President Trump on December 22, 2017.  Now that tax returns are being prepared for the 2018 year, individuals are more keenly feeling the impact of the “Tax Cuts and Job Act” (“TCJA”). I’ve had numerous calls on two questions by Americans overseas who own a foreign residence.  … Continue reading Overseas Home? Mortgage Interest, Foreign Real Property Taxes & New US Tax Law – Any Workaround?